PATRICIA MCCLANAHAN

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141/HR 2167, Automatic IRA Act of 2007; S. 1010/HR 2205, Retirement Security for Life Act of 2007; S. 2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;

Pension Protection Act implementation; Wrap fee revenue ruling request; 529 plan regulatory project; PRM on Sec. 408(b)(2) of ERISA; RFI on disclosure to participants; Form 5500 revisions S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141 / HR 2167, Automatic IRA Act of 2007; S. 1010 / HR 2205, Retirement Security for Life Act of 2007; S.2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act 2007; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;

Patent Reform S. 1145; HR 1908; NASD/NYSE Merger; Rules to allow the booking of OTC Derivatives in a full service broker dealer; Portfolio Margining; Delta Hedging; Strengthening US Competitiveness; Basel II/Consolidated Supervision Entities Regulatory framework; Prime Brokerage; Fee Based Brokerage; Soft Dollars, Client Commission Arrangements; 12B-1 Fees S. 1677 (International Economic Coordination/Market Access); S. 577 (OTC Derivatives); Secondary Market and Subprime Mortgage Financing; HR 2 (Contingent Convertible Debt); Tax Credit Bonds and Public Private Partnerships; Hedge funds, private pools of capital, asset management issues; Arbitration and Litigation Reform; HR 1443 (Consumer Fairness Act of 2007); HR 888 (Business Facilitation Act)

S. 2242, HR 2419, Denial of deduction for certain settlement payments; HR 3996, HR 3970, HR 6, HR 878, S. 601, Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242, HR 2419, HR 3970, HR 4351, Codification of economic substance doctrine; HR 1509; S 902; permanence of active financing exception under Subpart F;

Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Codification of economic substance doctrine and associated penalty proposals; Low rate on dividends of individuals; Foreign tax credit rules (including proposed “technical taxpayer” rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration’s project on tax intermediaries; OECD project on provision of treaty withholding tax relief when investment is made through collective investment vehicles ; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Valuation safe harbor under IRC section 475 mark-to-market requirements; Application of FIRPTA to debt exchangeable into REIT shares; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools HR 2; HR 1591; HR 2206, Tax treatment of contingent convertible debt; Denial of deduction for certain settlement payments; limitation on nonqualified deferred compensation plans; expansion of definition of covered employee under IRC section 162 (m); Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); Codification of economic substance doctrine; HR 1509; S 902; permanence of active financing exception under Subpart F;

HR 964, Securely protect yourself against cyber trespass or SPY Act; HR 1525, Internet Spyware (I-SPY) Prevention Act; S. 1625 (Counter Spy Act); S. 1691 (Social Security Number Online Protection Act); S. 2168 (Identity Theft Enforcement and Restitution Bill): HR 3046 (Social Security Number and Identity Theft Prevention Act)

HR 1685 (Protect Information Relating to Consumers to Require Notice of Security Breaches); S. 1260 (Data Security Act); HR 958 (Data Accountability and Trust Act); S. 1202 (Personal Data Act of 2007); S. 239 (Notification of Risk to Personal Data Act of 2007); S. 495 (Personal Privacy Data and Security Act); S. 1178 (Identity Theft Prevention Act); HR 948 (Social Security Number Protection Act); HR 3915 (Mortgage Reform and Anti-Predatory Lending Act);

HR 1685 (Protect Information Relating to Consumers to Require Notice of Security Breaches); S. 1260 (Data Security Act); HR 958 (Data Accountability and Trust Act); S. 1202 (Personal Data Act of 2007); S. 239 (Notification of Risk to Personal Data Act of 2007); S. 495 (Personal Privacy Data and Security Act); S. 1178 (Identity Theft Prevention Act); HR 948 (Social Security Number Protection Act); Basel; HR 698 (Industrial Loan Companies); S. 1299 (Subprime Lending)

Patent Reform S. 1145/HR 1908

Patent Reform S. 1145; HR 1908; NASD/NYSE Merger; Rules to allow the booking of OTC Derivatives in a full service broker dealer; Portfolio Margining; Delta Hedging; Strengthening US Competitiveness; Basel II/Consolidated Supervision Entities Regulatory framework; Prime Brokerage; Fee Based Brokerage; Soft Dollars, Client Commission Arrangements; 12B-1 Fees S. 1677 (International Economic Coordination/Market Access); S. 577 (OTC Derivatives); Secondary Market and Subprime Mortgage Financing; HR 2 (Contingent Convertible Debt); Tax Credit Bonds and Public Private Partnerships; Hedge funds, private pools of capital, asset management issues; Arbitration and Litigation Reform; HR 1443 (Consumer Fairness Act of 2007); HR 888 (Business Facilitation Act)

S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141/HR 2167, Automatic IRA Act of 2007; S. 1010/HR 2205, Retirement Security for Life Act of 2007; S. 2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;

Pension Protection Act implementation; Wrap fee revenue ruling request; 529 plan regulatory project; PRM on Sec. 408(b)(2) of ERISA; RFI on disclosure to participants; Form 5500 revisions S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141 / HR 2167, Automatic IRA Act of 2007; S. 1010 / HR 2205, Retirement Security for Life Act of 2007; S.2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act 2007; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;

Pension Protection Act implementation; Wrap fee revenue ruling request; 529 plan regulatory project; PRM on Sec. 408(b)(2) of ERISA; RFI on disclosure to participants; Form 5500 revisions S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141 / HR 2167, Automatic IRA Act of 2007; S. 1010 / HR 2205, Retirement Security for Life Act of 2007; S.2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act 2007; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;

S. 819/HR 1419, Public Good IRA Rollover Act of 2007; S. 1141/HR 2167, Automatic IRA Act of 2007; S. 1010/HR 2205, Retirement Security for Life Act of 2007; S. 2, Fair Minimum Wage Act of 2007; S. 1725, Restoring Pension Promises to Workers Act; S. 1288, Women's Retirement Security Act of 2007; HR 2669, College Cost Reduction Act of 2007; HR 2831, Ledbetter Fair Pay Act of 2007; Pension technicals; Fee disclosure and transparency; Small business pension coverage;